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Establishing the residency of artificial persons in cross border transactions
Includes bibliographical references.
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| Main Author: | |
|---|---|
| Format: | Thesis |
| Language: | English |
| Published: |
Department of Commercial Law
2014
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| _version_ | 1867613320331132928 |
|---|---|
| access_status_str | Open Access |
| author | Tanyanyiwan, Vimbai |
| author_browse | Tanyanyiwan, Vimbai |
| author_facet | Tanyanyiwan, Vimbai |
| author_sort | Tanyanyiwan, Vimbai |
| collection | Thesis |
| description | Includes bibliographical references. |
| format | Thesis |
| id | oai:open.uct.ac.za:11427/9614 |
| institution | University of Cape Town (South Africa) |
| language | eng |
| last_indexed | 2026-06-10T12:34:14.045Z |
| license_str | Not specified — see source repository |
| provenance_str_mv | Harvested via OAI-PMH from UCTD — University of Cape Town Open Access Repository |
| publishDate | 2014 |
| publishDateRange | 2014 |
| publishDateSort | 2014 |
| publisher | Department of Commercial Law |
| publisherStr | Department of Commercial Law |
| record_format | dspace |
| source_str | UCTD — University of Cape Town Open Access Repository |
| spelling | oai:open.uct.ac.za:11427/9614 Establishing the residency of artificial persons in cross border transactions Tanyanyiwan, Vimbai Includes bibliographical references. The basis of residence taxation is that residents enjoy protection in the state where they contribute towards the costs of government. In tax treaties residence is used for purposes of allocating income and taxing rights between contracting states. For treaty purposes residence is determined on a day to day basis, hence a person can be resident in two countries at concurrent time periods. It is important to determine the residence of a corporation in a specific jurisdiction for purposes of ascertaining the treaty benefits that the entity can enjoy and the allocation of income between contracting states in a treaty. Usually a company’s tax residence is considered to create a sufficient connection with the country that has jurisdiction over it. The recognition of the residence status of natural and juristic persons is the cornerstone of international taxation. Residence is also used as an antiavoidance tax measure in international tax. 2014-11-14T19:48:08Z 2014-11-14T19:48:08Z 2014 Master Thesis Masters LLM http://hdl.handle.net/11427/9614 eng application/pdf Department of Commercial Law Faculty of Law University of Cape Town |
| spellingShingle | Tanyanyiwan, Vimbai Establishing the residency of artificial persons in cross border transactions |
| thesis_degree_str | Master's |
| title | Establishing the residency of artificial persons in cross border transactions |
| title_full | Establishing the residency of artificial persons in cross border transactions |
| title_fullStr | Establishing the residency of artificial persons in cross border transactions |
| title_full_unstemmed | Establishing the residency of artificial persons in cross border transactions |
| title_short | Establishing the residency of artificial persons in cross border transactions |
| title_sort | establishing the residency of artificial persons in cross border transactions |
| url | http://hdl.handle.net/11427/9614 |
| work_keys_str_mv | AT tanyanyiwanvimbai establishingtheresidencyofartificialpersonsincrossbordertransactions |